S. R. NAYAK, J. ( 1 ) THE Customs, Excise and Gold (Control) Appellate Tribunal, South Regional Bench, Madras (for short cegat ) has referred the following question to this Court under Section 35-G of the Central Excise Act, 1944, (for short the Act ) at the instance of the assessee. "whether the Tribunal is correct in holding that the items Wire Mesh and Woolen Felts are not inputs under Rule 57-A of CE Rules, 1944, inspite of specific exclusion as given therein and the items in question do not come under that category for the reasons set out in the order ?"the Sirpur Paper Mills Limited (for short the Company ) are the manufacturers of papers and paper Boards in their factory at Sirpur Kaghaznagar in Andhra Pradesh. Their final products fall under Chapter 48 of the Central Excise Tariff. They are availing MODVAT under Rule 57-A of the Central Excise Rules, 1944 (for short the rules ) relating to MODVAT Credit Scheme in respect of the following items after filing the declaration dated 31-3-1987 in terms of Rule 57 (g) of the Rules: (i) Machine wire (ii) Dandy Roll Covers (iii) Felts (iv) Chipper Knives and (v) Cutter knives. The Superintendent of Central Excise, Range I, Sirpur Kaghaznagar issued show-cause notice dated 18-9-1987 on M/s. Sirpur Paper Mills Limited asking them to show-cause to the Assistant Commissioner of Central Excise, Warangal as to why an amount of Rs. 1,86,164. 16 being the MODVAT credit availed by them for the months April, 198 7/08/1987 on certain inadmissible items like Chipper Knives, Mesh Wire, Felts etc. , under the provisions of Rule 57 (1) of the Rules. In the show-cause notice, it was stated that the Company filed a declaration under their letter No. SX/57a/6094/11718, dated 31-3-1987 to avail MODVAT credit on five inputs such as Machine wires. Dandy roll covers, felts, chipper knives and clutter knives. The above declaration of the Company was forwarded to the Superintendent of Central Excise, Range I, who was in-charge of the factory and asking him to verify the declaration of the Company to send a report to the Office of the Assistant Collector, Central Excise, Warangal. Accordingly, the Superintendent of Central Excise, Range I, caused verification of the declaration and found the above items and inadmissible for MODVAT Credit and in those circumstances the show-cause notice was issued. Accordingly, the Superintendent of Central Excise, Range I, caused verification of the declaration and found the above items and inadmissible for MODVAT Credit and in those circumstances the show-cause notice was issued. The Company received that show-cause notice on 23-9-1987 and replied to the show-cause notice on 24-10-1987. In the reply submitted by the Company, it contended that the show-cause notice issued is contrary to the provisions of the Act and the rules and without jurisdiction, the MODVAT credit availed by the Company are as per Rule 57-A and as per Notification No. 177/ 86-CE as amended from time to time. MODVAT credit is available on the notified inputs, inasmuch as they are used in or in relation to the manufacture of the final products; Machine wires, Dandy roll covers, felts, Chipper knives, Cutter knives fall under sub-heading Nos. 7413. 90; 5909. 00; 8203. 80 and 5203. 90 respectively and therefore since those items are inputs notified under Notification No. 177/86-Central Excise and fall under sub-heading Nos. 7413. 90; 5909. 00; 8203. 80 and 5203. 90, it could not be said that the Company have availed MODVAT credits wrongly. The Assistant Collector, vide Order No. V/48/30/4/87/mp II (PF), dated 9-2-1988 disallowed the MODVAT credit to the Company and affirmed the demand raised by the Superintendent of Central Excise - Range I, in his notice dated 18-9-1987. On appeal by the Company, the Collector of Central Excise (Appeals) vide Order No. 227/88 (H) dated 29-7-1988 confirmed the order of the Assistant Collector. The further appeal to the CEGAT confining the challenge to wire mesh and woolen felts only was also dismissed by the CEGAT by order No. E/419/89, dated 26-3-1991 relying on the earlier order No. 299/90 dated 4-4-1990 of the Bench of CEGAT wherein it was held:"it has to be concluded that the credit has to be allowed only in respect of such of those inputs which are used in the process of manufacture and which go directly into the manufacturing stream by themselves are used in the manufacture of materials which go into the manufacturing stream resulting in the manufacture of the end product. The parts of the machines which produce the finished goods do not pass this criterion and in that view of the matter we hold that the appellants have rightly been denied the MODVAT credit. The parts of the machines which produce the finished goods do not pass this criterion and in that view of the matter we hold that the appellants have rightly been denied the MODVAT credit. "hence, this reference under Section 35-G of the Act at the instance of the appellant Company. ( 2 ) WE have heard Sri C. Kodandaram, learned Counsel for the petitioner and learned senior Standing Counsel of the Government of India. ( 3 ) THE resolution of the controversy in this reference depends on the correct understanding of provisions of Rule 57-A relating to MODVAT Credit Scheme. The said scheme enables manufacturers of specified final products to avail credit of specified duty paid on specified goods (referred to as "inputs") used in or in relation to the manufacture of the said final products and to utilize such credit towards payment of excise duty leviable on the final products under the Act or under any other Act as may be specified. The provision is subject to the provisions of the other rules in the section and restrictions that may be specified. Rule 57-A reads as follows:"57-A. The provisions of this section shall apply to such finished excisable goods (hereinafter referred to as the "final product"), as the Central Government may, by notification in the Official Gazette, specify in this behalf, for the purpose of allowing credit of any duty of excise or the additional duty under Section 3 of the Customs Tariff Act, 1975 (51 of 1975), as may be specified in the said notification (hereinafter referred to as the "specified duty") paid on the goods used in or in relation to the manufacture of the said final products (hereinafter referred to as the "inputs") and for utilizing the credit so allowed towards payment of duty of excise leviable on the final products, whether under the Act or under any other Act, as may be specified in the said notification, subject to the provisions of this section and the conditions and restrictions that may be specified in the notification : Provided that the Central Government may specify the goods or classes of goods in respect of which the credit of specified duty may be restricted. EXPLANATION :--For the purposes of this rule, "inputs" includes- (a) inputs which are manufactured and used within the factory of production in or, in relation to the manufacture of final products; and (b) paints and packaging materials; but does not include- (i) machines, machinery, plant, equipment, apparatus, tools or appliances used for producing or processing of any goods or for bringing about any change in any substance or in relation to the manufacture of the final products; (ii) packaging materials in respect of which any exemption to the extent of the duty of excise payable on the value of the, packaging materials is being availed of for packaging any final products; (iii) packaging materials the cost of which is not included or had not been included during the preceding financial year in the assessable value of the final products under Section 4 of the Act; (iv) cylinders for packaging gases; or (v) plywood for tea chests. " The question to be resolved in the light of the provisions of Rule 57-A is whether Wire Mesh and Woolen felts are "inputs" within the meaning of that term for the purpose of Rule 57-A or they fall under the excluded category. Rule 57-A itself defines inputs as "goods used in or in relation to the manufacture of the said final products. " In J. K. Cotton Spinning and Weaving Mills Company Limited v. STO, AIR 1965 SC 1310 , which case arose in the context of the provisions of Sales Tax Act and the rules framed thereunder, the Supreme Court held;"the expression in the manufacture of goods should normally encompass the entire process carried on by the dealer of converting raw materials into finished goods. Where any particular process is so integrally connected with the ultimate production of goods that but for that process, manufacture or processing of goods would be commercially inexpedient, goods required in that process would, in our judgment, fall within the expression in the manufacture of goods . "the Apex Court having given the example of the various processes, raw cotton is subjected to before it is converted into yarn and yam is converted into textiles, indicated that the processes would be regarded as integral processes and included in the "manufacture" of cloth. "the Apex Court having given the example of the various processes, raw cotton is subjected to before it is converted into yarn and yam is converted into textiles, indicated that the processes would be regarded as integral processes and included in the "manufacture" of cloth. The Court further observed as follows: "in our judgment if a process or activity is so integrally related to the ultimate manufacture of goods so that without that process or activity manufacture may, even if theoretically possible, be commercially inexpedient, goods intended for use in the process or activity as specified in Rule 13 will qualify for special treatment. " ( 4 ) IN Doypack Systems (Private) Limited v. Union of India, 1988 (36) ELT 201 , the Apex Court while considering the expressions "pertaining to. " "in relation to" and "arising out of occurring in Section 4 (1) of the Swadeshi Cotton Mills Company Limited (Acquisition and Transfer of Undertakings) Act, 1986, held that they are used in the expansive sense and they are interchangeable. The Apex Court held as follows:"the expression in relation to (so also pertaining to ), is a very broad expression, which pre-supposes another subject-matter. There are words of comprehensiveness which might both have a direct significance as well as an indirect significance depending on the context. . . . . . . . In this connection reference may be made to 76 Corpus Juris Secundum at pages 620 and 621 where it is stated that the term "relate" is also defined as meaning to bring into association or connection with. It has been clearly mentioned that "relating to" has been held to be equivalent to or synonymous with as to concerning with and pertaining to . ( 5 ) IN Collector of Central Excise v. Ballapur Industries Limited, 1989 (43) ELT 804 , the assessee was manufacturing paper and paper board Sodium Sulphate was used in the chemical recovery cycle of Sodium Hydroxide and Sulphine which formed essential constituents of sulphate cooking liquor used at the stage of digestion of the pulp. But Sodium Sulphate did not become part of paper. It would be burned up in the process. The claim of assessee was for exemption from payment of excise duty on sodium sulphate as "raw material or component part" of the finished product on the basis of Notification dated 28-2-1982. But Sodium Sulphate did not become part of paper. It would be burned up in the process. The claim of assessee was for exemption from payment of excise duty on sodium sulphate as "raw material or component part" of the finished product on the basis of Notification dated 28-2-1982. The said notification granted exemption to all excisable goods on which excise duty was leviable and in the manufacture of which any goods falling under Item 68 of Excise tariff have been used as raw material or component parts. The goods so used were referred to as "inputs" Exemption was of so much of excise duty as was equivalent to the excise duty paid on the inputs. The question was whether sodium sulphate could be said to have been used as "raw material" in the manufacture of paper or paper board. In that context, the Supreme Court held:". . . . . . . THAT the ingredients should be so essential for the chemical processes culminating in the emergence of the desired end-product, that, having regard to its importance in and indispensability for the process, it could be said that its very consumption on burning up is its quality and value as raw material. In such a case, the relevant tests is not its presence in the end-product, but the dependence of the end-product for its essential presence at the delivery end of the process. The ingredient goes into the making of the end-product in the sense that without its absence the presence of the end-product, as such, is rendered impossible. This qualify should coalesce with the requirement that its utilization is in the manufacturing process as distinct from the manufacturing apparatus. "the Apex Court, referring to the decision in Deputy Commissioner of Sales Tax v. Thomas Stephen and Company Limited, 1988 (34) ELT 416 , (SC), where it was held that cashew shells used as fuel in the Kiln used for manufacture of tiles as "goods consumed in the manufacture of other goods" under Section 5-A (1) (a) of Kerala General Sales Tax Act, 1963, opined that the observation therein to the effect that -- "these (cashew shells) have not been used as raw materials in the manufacture of the goods. These have been used only as an aid in the manufacture of the goods by the assessee. These have been used only as an aid in the manufacture of the goods by the assessee. Consumption must be in the manufacture as raw-material or of other components which go into the making of the end-product to come within the mischief of the section. Cashew shells do not tend to the making of the end product. "- were made to emphasise the distinction between "fuel" used for Kiln to impart the heat treatment to tiles and what actually went into the manufacture of such tiles and do not mean that for something to qualify itself as "raw material" it must necessarily and in all cases go into, and be found, in the end product. So opining, the Apex Court held that sodium sulphate was used in the manufacture of paper as "raw material within the meaning of the Notification dated 28-2-1982. In Singh Alloys and Steels Limited v. Assistant Collector of Central Excise, 1993 (66) ELT 594 , the High Court of Calcutta while reviewing the opinion of the Tribunal that refractory, reaming mass and fire clay used for lining the furnace and ladles for heat resistance are not eligible for Modvat credit, held that the said opinion of the Tribunal was erroneous. In that case, Ramining mass and Dolopatch mix classified as miscellaneous chemical products under Chapter 38 Heading 316. 00 and Manganese peas (classified under Heading 28. 20) are first charged into the furnace as fettling materials and to dissolve and seal the crevices in the refractory walls of the furnace to prevent leading of the liquid metal from the furnace and to reduce the erosion of the refractory lining of the furnace and use their identity and are consumed in the process. Some parts of these articles remain in the liquid metal and balance forms part of the residue or slug. Some parts of these articles remain in the liquid metal and balance forms part of the residue or slug. Keeping in mind the factual matrix of that case, the Calcutta High Court held that ramming mass, dolopatch mix and manganese peas are "inputs" within the meaning of the Rule 57-A. The Court opined that the crucial question is -- "are the items inputs at all in respect of steel ingots?" and if the question is answered in the affirmative, the next question is "are the items within the excluded inputs?" The Calcutta High Court observed :"analysing the meaning of inputs as provided in the explanation it would appear that everything is an input if it is (i) manufactured and used within the factory of production or (ii) used in relation to the manufacture of the final products, and, (iii) paints and packaging material. The exceptions relate to items which would otherwise have come within the inclusive definition of inputs. "the Calcutta High Court further observed:"the subject of the Legislature appears to me to be to exclude from the genus of inputs, the species mentioned in the excluded categories because otherwise a manufacture would be entitled to claim Modvat in respect of such inputs repeatedly as these would not be inputs which would be consumed in the process of manufacture. This is clear from a scrutiny of the excluded items. "the Calcutta High Court further held that these inputs do not fall within the dictionary meaning of "machine, machinery, instrument or appliance" and are chemicals used for the machinery. The Calcutta High Court proceeds to hold: "it does not matter that the items are used in the machinery or for the purpose of the machinery. To repeat, the only relevant question is, are they used in or in relation to the manufacture of ingots. "having so opined, the Calcutta High Court found fault with the reasoning of the Tribunal in seeking to limit the meaning of the word "inputs" to those items which go into the steel ingot completely overlooking the phrase "in relation to" occurring in the Explanation to Rule 57-A. In Ponds (India) Limited v. Collector of Central Excise, 1993 (63) ELT 3 , the appellant, manufacturer of cosmetics, used duty paid plastic granules to manufacture plastic containers and used the same as containers for the excisable final product, namely, cosmetics. The High Court of Madras held that the cosmetic items are not marketable unless packed in containers which have to be treated as component part of the final product and that wider connotation should be given to the words "goods used in or in relation to the manufacture" of final product. Plastic granules would be component parts of the final product. ( 6 ) IT is trite, under Rule 57-A, inputs are not only goods used in the manufacture of final products, but also goods used in relation to the manufacture of final products. The same language is used in exclusion Clause (i) of the Explanation to Rule 57-A. In J. K. Cotton Spinning and Weaving Mills Co. Limited s case (supra) the words "goods. . . . . . . . . . . used by him (dealer) in the manufacture or processing of goods" occurring in Section 8 (3) (b) of the Central Sales Tax Act and Rule 13 of the Rules have been held by the Supreme Court to take in not only the process of production of goods but also all processes which are directly related to the actual production. The Court held that there was no warrant for limiting the meaning of the expression "in the manufacture of goods". In Doypack Systems (Pvt.) Limited v. Union of India, (supra), the Supreme Court held that the words "in relation to" occurring in Section 4 (1) of the Swadeshi Cotton Mills Company Limited (Acquisition and Transfer of Undertakings) Act, 1956 are very broad expressions and to be of comprehensiveness which might have both a direct significance as well as an indirect significance depending on the context. These words have been held to be equivalent to or synonymous with "concerning with" and "pertaining to". ( 7 ) THE Rule-making authority, in our opinion, has incorporated the words "in relation to the manufacture" in Rule 57-A to widen and expand the scope, meaning and content of the expression "inputs" defined in the Explanation to Rule 57-A. It is recognised rule of interpretation of Statutes that expression used in a Statute should ordinarily be understood in a sense in which they best harmonise with the object of the statute, and which effectuate the object of the Legislature or the Rule-making authority. Therefore, when two interpretations are feasible, the Court will prefer that which advances the remedy and suppresses the mischief as the Legislature or the Rule making authority, as the case may be, envisioned The provisions of Rule 57-A in one sense remedial as well as exemptrating. It is well established principle of interpretation that a taxing statute is to be strictly construed. This well -established rule in the familiar words of Lord Wensleydale, in Re, Micklethwait, (1885) 11 Ex. 452, P. 456, reaffirmed by Lord Halsbury in Tenant v. Smith, (1892) AC 150, P. 154, and Lord Simonds in St. Aubyn v. A. G. , (1951) 2 All ER 473, p. 485 (HL), and referred to with approval by the Supreme Court in Member Secretary, Andhra Pradesh State Board for Prevention and Control of Water Pollution v. Andhra Pradesh Rayons Limited, AIR 1989 SC 611 , p. 614, and in Saraswati Sugar Mills v. Haryana State Board, AIR 1992 SC 224 , p. 228, means: "the subject is not to be taxed without clear words for that purpose; and also that every Act of Parliament must be read according to the natural construction of its words. " In a classic passage Lord Cairns stated the principle in Partington v. A. G, (1869) LR 4 HL 100, p. 122, thus:"if the person sought to be taxed comes within the letter of the law he must be taxed, however, great the hardship may appear to the judicial mind to be. On the other hand, if the Crown seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of law the case might otherwise appear to be. In other words, if there the admissible in any statute, what is called an equitable, construction, certainly, such a construction is not admissible in a taxing statute where you can simply adhere to the words of the statute. "the above observation of Lord Cairns was referred to with approval in IRC v. Duke of Westminister, (1936) AC 1, P. 24 (HL), Ransom (Inspector of Taxes) v. Higgs, (1974) 3 All ER 949 p. 970 (HL) and the Privy Council in Bank of Chettinad v. CIT, AIR 1940 PC 183, J. K. Steel Limited v. Union of India, AIR 1970 SC 1173 . The rule of strict construction does not negative the application of the well-known principle that a person who claims an exemption has to establish it, and there is ample authority for the view that this principle applies to exemptions granted in taxing laws as well. Reference may be made usefully to CIT v. Ramakrishna Deo, AIR 1959 SC 239 , Kedarnath Jute Manufacturing Company Limited v. Commercial Tax Officer, Shyam Bazar, AIR 1966 SC 12 , Controller of Estate Duty v. V. Venugopal Varma Rajah, AIR 1977 SC 121 , P. A. Thillai Chidambara Nadar v. Additional App. Asst. Commissioner, (1985) 4 SCC 30 = AIR 1985 SC 1644 , Mangalore Chemicals and Fertilisers Limited v. Deputy Commissioner of Commercial Taxes, AIR 1992 SC 152 , in that regard. It is well-established that the exemptions made with a beneficent object e. g. , to give incentive to co-operative movement In Tata Oil Mills Co. v. Collector of Central Excise, AIR 1990 SC 27 , the Supreme Court held that if the object of an exemption notification is to encourage the use of indigenous rice bran oil and to discourage the use of edible oils in soap manufacture, a narrow construction of the notification which defeats this object cannot be accepted and preference has to be given to a wider construction which promotes the object. In Oblum Electrical Industries Private Limited, Hyderabad v. Collector of Customs, Bombay, AIR 1997 SC 3467 , the Supreme Court dealing with the object to encourage exports by granting exemption from customs duty on materials that are needed for the manufacture of the resultant product, opined that the words "material required to be imported for the purpose of manufacture of products" included not only materials which are actually used in the manufacture but also materials which though not used in the manufacture are yet required in order to manufacture the resultant product. In Collector of Central Excise v. Neoli Sugar Factory, AIR 1993 SC 1921 , where the exemption notification granting rebate in excise duty to induce the manufacturers of sugar to produce more in the then current sugar year than they had produced during the corresponding period, during the previous year was provided and considering that exemption, the Supreme Court held that the construction of exemption notification should be consistent with the object of the notification and that the words "the quantity of sugar produced during the corresponding period" as used in the notification were construed to cover the case of a factory which has not produced at all during the relevant corresponding period. In Swadeshi Polytex Limited v. Collector of Central Excise, AIR 1990 SC 301 , the Court held that an exemption provision cannot be denied full effect by a circuitous process of interpretation. Further, in Indian Farmers Fertiliser Co-operation Limited v. Collector of Central Excise, AIR 1996 SC 2542 , the Court held that liberal language used in a notification must be given due weight. Thus, it is well-settled position in law that if the tax-payer is within the plain terms of the exemption notification, he cannot be denied the benefit calling in aid, any supposed intention, an the language of the notification has to be given effect to. ( 8 ) THE words "in relation to the manufacture" occurring in Rule 57-A are clear, unambiguous and, therefore, full effect must be given to those words by interpretation process. The deliberate design of the Rule-making authority cannot be frustrated and the words and expression "used in relation to the manufacture" must be allowed its natural play. Raw materials, as commonly understood, are used in the mainstream of entire process of converting raw materials into finished products or any other process integrally connected with the ultimate production of finished products. If that is so, the question to be considered is what is the purpose of interpreting the words "in relation to the manufacture" in Rule 57-A? In our considered opinion, the purpose, undoubtedly, is to widen further the scope, ambit and content of the term "inputs". In other words, the purpose is to widen the ambit so as to attract also goods which do not enter directly or indirectly into the finished product, but are used in any activity concerned with or pertaining to the manufacture of finished goods. In other words, the purpose is to widen the ambit so as to attract also goods which do not enter directly or indirectly into the finished product, but are used in any activity concerned with or pertaining to the manufacture of finished goods. ( 9 ) THE two items in question viz. , wire mesh and woolen felts, it is stated, are used in the paper machine section of the paper mill to maintain the machinery functional. Pulp with excess water comes from the pulp making machine to the paper making machine. Pulp is allowed to fall on phosphor bronze or stainless steel wire mesh. Pulp articles remain on the wire mesh and web of pulp fiber is formed. It moves on moving wire mesh and is allowed to fall on felt (cotton, woolen or synthetic ). The moving felt carries the pulp web to the drier and is calendered or pressed being wound on rolls and treated further. It is also stated that the above articles are damaged in the process and required replacement periodically. These articles are replaceable goods used in the paper-making machine in the course of manufacture of paper. It is true that wire mesh and woolen felts can be regarded in a way, as parts of the paper making machine or machinery used in the manufacture or for the purpose of the machine. But, at the same time, by their very purpose, wire mesh and woolen felts are goods used in relation to the manufacture of paper or paper products and if there is so they can undoubtedly be treated as "inputs" within the contemplation of Rule 57-A in the light of the judgments of the Supreme Court considered above and that of the Calcutta High Court in Singh Alloys and Steels Limited (supra ). Having regard to the manner in which and the purpose for which wire mesh and woolen felts are used in the machines in the manufacture of paper and paper products, they are to be held as parts of machines not comprehended by the exclusion Clause (i) of the Explanation to Rule 57-A. Therefore, spares of such goods cannot be regarded as falling within exclusion Clause (i ). Wire mesh and woolen felts used in the manufacture of paper themselves cannot be treated as tools or machines that are used to carry out the specific function nor could it be treated as "equipments" that draws any energy in producing a desired result. ( 10 ) WE are in respectful agreement with the view taken by the Calcutta High Court in Singh Alloys and Steels Limited (supra ). In that case, the goods which are not raw materials converted into finished products, but which are charged into furnace as fettling materials to dissolve and seal the crevices in the refractory walls of the furnace and are consumed in the process have been held to be goods used "in relation" to the manufacture of finished goods. The Calcutta High Court explained that the exclusion clauses of the Explanation to Rule 57-A relate to items which would otherwise have come within the definition of inputs. This would mean that machine, machinery and other goods referred to in exclusion Clause (i) would, but for the exclusion, fall within the ambit of the expression "inputs", that is, "goods used in relation to the manufacture of finished products". The Calcutta High Court stated that it does not matter that the goods are used in the machinery or for the purpose of the machinery. What is relevant is whether the goods used are "in relation" to the manufacture of finished goods and if the answer is in the affirmative, such goods will fall within the exempted category. ( 11 ) VARIOUS expressions are used in exclusion Clause (i) of the Explanation to Rule 57-A of the Rules, viz. , machines, machinery, plant equipment, apparatus, tools or appliances used for producing or processing of any goods or for bringing about any change in any substance in or in relation to the manufacture of final products. In Mcgraw-Hill Dictionary of Scientific and Technical Terms, IV Edition, the above terms are defined as follows:apparatus :--A compound instrument designed to carry out a specific function Appliance :--A piece of equipment that draws electric or other energy. Equipment :--One or more assemblies capable of performing a complete function. Machine :--A mechanical, electric or electronic device, a combination of rigid or resistant bodies having definite motion and capable of performing useful work. Machinery :--A group or parts of Machines arranged to perform a useful function. Equipment :--One or more assemblies capable of performing a complete function. Machine :--A mechanical, electric or electronic device, a combination of rigid or resistant bodies having definite motion and capable of performing useful work. Machinery :--A group or parts of Machines arranged to perform a useful function. Plant:--The land, buildings and equipment used in an industry. In Academic Press Dictionary of Science and Technology, the above terms are defined as follows: Appliance:--In general, any tool or machine that is used to carry out a specific task or produce a desired result. Machine :--Any device that transmits or modifies energy, an assembly of interrelated parts, each with a definite motion and separate function. Machinery :--A group of parts of machines that are arranged to perform a particular operating or machining function. Plant:--An engineering production facility, a factory, electric power station or the like. Tool :--A portable and usually hard-held instrument that is used to increase the efficiency of a work effort. In Words and Phrases, Permanent Edition -Vol 7-A, the above terms are defined as follows: Apparatus :--It means a collection or set of materials, implements or utensils for a given work, a complex device or machine or a set of tools, appliances, any complex instrument for a specific action or operation, machinery or mechanism. Appliance :--is generally considered to be any house hold or office utensil, apparatus or instrument or machine that utilizes a power supply, especially electric current e. g. , vacuum cleaners refrigeration, toaster, air-conditioner. Machine :--is a mechanical contrivance that modifies, utilizes or applies energy of force for a useful purpose or function. It includes every mechanical device or contrination of mechanical powers and devices used to perform some functions or and produces a certain effect or result. Machinery :--means machines in general or collectively; also the working parts of a machine, engine or instrument; as the machinery of a watch. The means and appliances by which anything is kept in action or a desired result is obtained; a system of parts adopted to a purpose. Plant :--is an all embracing term expressive of land, buildings, and the equipment of the business conducted on the premises. Plant is an entity itself, wholly distinct from the land, buildings, machinery and appliances which compose it. Plant :--is an all embracing term expressive of land, buildings, and the equipment of the business conducted on the premises. Plant is an entity itself, wholly distinct from the land, buildings, machinery and appliances which compose it. Tool :--An instrument of manual operation, like a human saw, plane, file or the like used to facilitate mechanical operations, as distinguished from an appliance moved by and regulated by machinery. ( 12 ) THE Privy Council in Corporation of Calcutta v. Chairman of the Cossipore and Chitpore, AIR 1922 PC 27, while holding that steel tank with its supporting structure for storage of water is not "machinery" within the meaning of proviso 3of Section 10 of the Bengal Municipal Act opined that a completed machine or a number of completed machines may, of course, according to the ordinary use of language, be properly described as "machinery", so may those parts or members of a machine which when assembled, as it is styled, form a complete machine so also may some such of those parts, which when assembled with the other necessary parts, would form a complete machine be styled as "machinery". The above decision of the Privy Council was followed by the Supreme Court in Commissioner of Income-tax v. Mir Mahammad Ali, AIR 1964 SC 1693 . In Rohit Pulp and Paper Mills Limited v. Collector of Central Excise, 1990 (47) ELT 491 , the exemption notification excluded five kinds of paper from the benefit of the exemption. It was found that four out of the five varieties of paper belong to the category of industrial paper. In the context, the Supreme Court held that the principle noscitur a sociis" according to which when two or more words which are susceptible of analogous meaning are coupled together they are understood to be used in their cognate sense, was applicable. Associated words take their meaning from one another under the principle of "noscitur a sociis". This principle is applied for ascertainment of the meaning of a doubtful word with reference to the meaning of words associated with it. From the definition of the words "apparatus, Appliance, Equipment, Machine, Machinery, Plant, and Tool" as noticed above, one could find a common thread which runs through all these definition and that common thread is the self-contained or complete nature of the goods. From the definition of the words "apparatus, Appliance, Equipment, Machine, Machinery, Plant, and Tool" as noticed above, one could find a common thread which runs through all these definition and that common thread is the self-contained or complete nature of the goods. Generally speaking, every one of the expressions take in self-contained, complete units or group of assemblage of parts. In other words, none of the expressions take in mere part unless it be that the part by itself is a self-contained or complete machine, apparatus, appliance, machinery, or tool. There cannot be any controversy that machine used for manufacture of specified fine products would be eligible input for the purpose of Rule 57-A, but for the exclusion Clause (i ). If that is so, the absence of specific reference to spare parts in the exclusion Clause (i) is of considerable significance. The Rule making authority in its wisdom deliberately and specifically did not incorporate spares in the exclusion Clause (i ). It is also relevant to note that wire mesh and woolen felts are to replace worn-out parts or parts which require replacement. Since the purpose of Rule 57-A is to grant benefit of MODVAT credit to manufacturers using specified goods in and in relation to the manufacture of specified final products and since the exclusion Clause (i) excepts not one but a group of items, there is no good reason to hold that only "self-contained, complete or whole" machines and not parts thereof are to be excluded. Having regard to the object and purpose of Rule 57-A, such a logically limiting restriction is required to be placed on the exclusion Clause (i) and such an interpretation becomes imperative particularly because of the absence of words "or parts thereof at the end of the exclusion Clause (i ). As could be seen from the exemption of various items and rule of Interpretation and section notes and Chapter notes in Schedule I to the Central Excise Tariff Act, the Parliament, while dealing with various kinds of machines and the like, specifically made provisions by way of Rule of interpretation to provide guidance in the matter of locating the actual position of spares and accessories among the various items, where the items do not specifically deal with spares and accessories. The total absence of any such feature in the exclusion Clause (i) in the Explanation to Rule 57-A of the Rules is, therefore, a clear pointer to the intention of the Rule-making authority not t bring spares within the ambit of the exclusion Clause (i ). ( 13 ) THE language of exclusion Clause (i) is plain, clear and precise. It carves out "machines, machinery, plant, equipment apparatus, tools or appliances. . . . . . . . ". These expressions indicate a self-contained unit, complete unit or whole unit but not any part thereof, unless such part is also a complete unit in itself. Therefore, it is not possible to infer the intention of the Rule-maker to exclude parts also along with machines, machinery etc. , and such an interpretation is not warranted either from the language used nor is it spelled out by necessary implication. ( 14 ) IN the result and for the foregoing reasons, we hold that wire mesh and woolen felts used in machinery in the manufacture of paper and paper products are eligible inputs under Rule 57-A of the Rules and that such inputs are not excluded by virtue of the exclusion Clause (i) of the Explanation to Rule 57-A. Consequently, we answer the question referred to us in the negative in favour of the assessee and against the Revenue. The RC is accordingly disposed of with no order as to costs.